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Comments of the Solar Energy Industries Association

D.P.U. 12‐120

A. The Need for Service Quality Metrics Related to the Utilities’ Adherence to Timelines for the Review of Interconnection Applications.

The Department of Public Utilities (DPU) model interconnection tariff specifies a timeline for utility completion of each of the major steps in the interconnection process. Utilities must adhere to these timelines in connection with their responsibility to process applications for interconnection to their networks. The various utility interconnection tariffs, based on the model tariff, all include this timeline. However, adherence to this timeline has not been consistent, and that inconsistency and unreliability has been a major obstacle for DG project development in the Commonwealth. 1 In recognition of this problem, the DPU convened the Distributed Generation Interconnection Working Group in docket 11‐75, and the legislature instructed the DPU to develop standards. 2 The DG Working Group delivered its recommendations to the department in September of 2012.

The DG Working Group emphasized two points above all else in its report, as necessary characteristics of an efficient and effective interconnection process that will foster continued growth of distributed generation in Massachusetts:

Customers applying to the interconnection process must know how long the steps in the process over which the interconnecting utility has control will take, and what the utilities’ technical interconnection standards will be, and those expectations must be reliably adhered to by the interconnecting utility; and

The interconnecting utilities, if they are to reliably adhere to those expectations, must be given sufficient time and sufficient resources to deliver.

The DG Working Group agreement had, at its core, a recognition by the non‐utility stakeholder that the utilities need to be allowed more time to process interconnection applications for the larger, more complex projects; and a corresponding recognition by the utilities that they have not implemented a system for transparently tracking compliance with each step of the tariff timelines, and that steps should be taken to better enforce the timelines in the tariffs. The non‐utility parties agreed to the longer timelines for complex projects that are included in the revision to the interconnection model tariff that was filed with the DPU on the explicit condition that the utilities agree to more concrete enforcement measures with respect those timelines. The entire working group agreed to the following language with respect to service quality metrics:

Utility Adherence (aka Assurance and Enforcement) to Timelines

The Working Group recommends a suite of measures to ensure and enforce utility compliance with tariff timelines.

A) Service Quality Metrics:

The Working Group believes that it is appropriate to explore the design of a service quality metric associated with enforcing timelines established in the Standards for Interconnection of Distributed Generation through a proceeding at the D.P.U. Moreover, the Working Group agrees to the inclusion of such a metric in the context of such proceeding and to have the metric be approved for effect as of January 1, 2014. The Working Group believes that the specific design of such metric must be based on the Department's articulated principles and protocols for establishing benchmarks based on objective and prospective empirical data and overall metric weighting, along with the clear recognition of the need for both utility and developers' mutual adherence to interconnection timelines. These and other aspects of a metric, including, but not limited to, whether a potential service nquality metric should include penalties and offsets based on 12 months performance in calendar year 2014 against a reasonable benchmark as determined by the Department, should be discussed in the context of the aforementioned D.P.U. proceeding. Nothing contained within this Report precludes the discussion and analysis of other comparable proposals relating to enforcing interconnection timelines in the context of this proceeding.3

SEIA’s position – and the reason we insisted on the measurement and enforcement components that we did in the working group – is that the utilities’ measurement of and compliance with the tariff timelines will improve when they have a clear business interest in improving them. This is not to cast any doubt on the intentions of the people in the relevant departments at the utilities, who have universally been collaborative, cooperative, and professional. But all private businesses focus on what matters to their business interests, so we have attempted to outline a structure through the DG Working Group that will incentivize the utilities to meet their obligations in the interconnection tariffs. The core of that structure is a service quality metric for compliance with the interconnection tariffs.

B. Benchmarking a Service Quality Metric for Processing of Interconnection Applications.

With respect to question 8 (Benchmarking for metrics), SEIA believes that a service quality metric for interconnection application review should be in effect as of January 1, 2014, as stipulated in the DG working group report. SEIA believes that simply by effectively measuring timeline compliance, which the utilities would have to do during a benchmarking year, performance will improve. However, SEIA is concerned that there would be no real business incentive for performance improvement during a benchmarking period, and in fact, that there would be a counterproductive incentive because the utilities would be setting the benchmark against which they will be measured in the future. Accordingly, SEIA recommends that a service quality metric for interconnection timeline compliance begin in earnest on January 1, 2014, that the Department set a modest, achievable performance target against which the utilities will pay penalties or generate offsets in the first year, and that the data from 2014 be used as a benchmark for subsequent years.

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SEIA appreciates the opportunity to comment on this matter. We look forward to working with the Department and the other stakeholders as this proceeding advances.

2 Massachusetts Bill S.2395, “An Act relative to competitively priced electricity in the Commonwealth” was signed by Governor Patrick on August 12, 2012, and stipulated that: The department of public utilities shall develop an enforceable standard interconnection timeline for the interconnection of distributed generation facilities. Timelines may vary depending on the size and type of the facility or other factors as determined by the department. The department shall implement such timeline not later than November 1, 2013. The department shall enforce established timelines as part of its service quality standards review under section 1I of chapter 164 or by whatever enforcement mechanism is determined appropriate by the department.

3 Proposed Changes to the Uniform Standards for Interconnecting Distributed Generation in Massachusetts; Submitted to: Massachusetts Department of Public Utilities in Compliance with DPU Order 11-75 by the Massachusetts Distributed Generation Interconnection Working Group Report , The DGWG Report); September 14, 2012. At pages 23-24. http://massdg.raabassociates.org/Articles/Final%20MA%20DG%20WG%20Report%...12.pdf